## Facts

- An Illinois 4-H club chartered a bus from an Illinois carrier for a round trip beginning and ending in Illinois, with travel to Michigan.
- The bus driver was an Illinois resident.
- The passengers (and certain spouses/parents bringing derivative claims) were Illinois residents.
- The bus left the roadway and overturned in Michigan, causing alleged injuries.
- Suit was filed in Illinois, and the dispute centered on whether Illinois or Michigan substantive law governed.

## Issues

1. In a tort action arising from a Michigan accident involving Illinois passengers, an Illinois bus company, and an Illinois resident driver under an Illinois-made charter for an Illinois-centered round trip, should an Illinois court apply Michigan law (place of injury) or Illinois law under the most-significant-relationship analysis?

## Decision

- The appellate court affirmed the trial court’s determination that Illinois substantive law governs.
- The court held Illinois had the most significant relationship to the occurrence and the parties.
- The court treated Michigan’s connection as largely limited to the accident location.

## Legal Principles

- Illinois applies the Restatement (Second) of Conflict of Laws “most significant relationship” approach in multistate tort cases, not a rigid place-of-injury rule.
- Choice of law requires weighing relevant contacts and the governmental interests of the states connected to the dispute.
- The place of injury is a factor but is not controlling when it is fortuitous and other contacts cluster strongly in another state.
- A state has a substantial interest in applying its law to regulate resident defendants and provide rules governing compensation for resident plaintiffs, particularly where the underlying relationship (e.g., a charter contract) is centered in that state.

## Conclusion

Because the contract, parties, and key relationships were centered in Illinois and Michigan’s principal connection was the accident’s location, Illinois was the state with the most significant relationship, and Illinois substantive law applied.


Schulze v. Illinois Highway Transportation Co., 97 Ill. App. 3d 508, 423 N.E.2d 278 (Ill. App. Ct. 3d Dist. 1981)